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Shreyas Sinha v. The West Bengal National University of Juridical Sciences & Ors.

Civil Appeal · 2020 INSC 541Decided 9 Sept 2020
Civil Appeal No. 3085 of 2020
Justice L. Nageswara Rao · Justice Hemant Gupta · Justice S. Ravindra Bhat

Background

A new law came into force on 21 May 2019 requiring the West Bengal National University of Juridical Sciences to reserve at least 30% of seats for students domiciled in West Bengal. The university's admission process for its five-year law course (via the CLAT entrance exam) had already begun in January 2019, before this amendment was passed, and by the time the law took effect, candidates had already made their university choices and some seats were already filled. The appellant, ranked 731st in the merit list, argued he should get the benefit of the new West Bengal domicile reservation for the 2019-2020 academic year. The university decided instead to apply the 30% reservation only from the following academic year (2020-2021), and both the Calcutta High Court's single judge and division bench upheld this decision.

Decision Breakdown

The Supreme Court held that since the admission process for 2019-2020 had already commenced before the amending Act came into force, and the Act itself did not specify from which academic year the reservation must apply, the university's decision to implement the 30% domicile reservation starting the next academic year was fair, reasonable, and not arbitrary. The Court distinguished the precedents cited by the appellant, noting he was not a "meritorious candidate" wrongly denied admission in the sense required by those earlier rulings, and that applying the new reservation mid-process would have unfairly disrupted the admissions of other students who had already made choices based on the old rules. The appeal was dismissed with no order as to costs.

Lesson Learnt

A new law or policy generally cannot be forced onto a process (like an admissions cycle) that has already started under the old rules, unless the law itself clearly says so: institutions are given reasonable latitude to apply new reservation requirements starting from the next fresh cycle rather than retroactively disrupting one already underway.

Official source (sci.gov.in)View Judgment (PDF)

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